Power to decide ownership, interpret contracts in ejectment cases
A defendant may not divest the MeTC of its jurisdiction by merely claiming
ownership of the property.[1] Under Section 16, Rule 70 of the Rules of Court, "[w]hen the
defendant raises the defense of ownership in his pleadings and the question of
possession cannot be resolved without deciding the issue of ownership, the
issue of ownership shall be resolved only to determine the issue of
possession." Section 18, Rule 70 of the Rules of Court, however, states that
"[t]he judgment x x x shall be conclusive with respect to the possession only
and shall in no wise bind the title or affect the ownership of the land or
building."
The authority granted to the MeTC to preliminarily resolve the issue of
ownership to determine the issue of possession ultimately allows it to
interpret and enforce the contract or agreement between the plaintiff and
the defendant. To deny the MeTC jurisdiction over a complaint merely because the issue
of possession requires the interpretation of a contract will effectively rule
out unlawful detainer as a remedy. As stated, in an action for unlawful
detainer, the defendant’s right to possess the property may be by virtue of a
contract, express or implied; corollary to this, the termination of the
defendant’s right to possess would be governed by the terms of the same
contract. Interpretation of the contract between the plaintiff and the
defendant is inevitable because it is the contract that initially granted the
defendant the right to possess the property; it is this same contract that the
plaintiff subsequently claims was violated or extinguished, terminating the
defendant’s right to possess. It was ruled in Sps. Refugia v.
CA[2] that –
[1] Consignado v. Court of Appeals, G.R. No. 87148, March 18, 1992, 207 SCRA 297, 305-306, citing De la Cruz v. Court of Appeals, G.R. No. L-57454, November 29, 1984, 133 SCRA 520, 528; and Ching v. Hon. Antonio Q. Malaya, etc., et al., G.R. No. 56449, August 31, 1987, 153 SCRA 412.
The authority granted to the MeTC to preliminarily resolve the issue of
ownership to determine the issue of possession ultimately allows it to
interpret and enforce the contract or agreement between the plaintiff and
the defendant. To deny the MeTC jurisdiction over a complaint merely because the issue
of possession requires the interpretation of a contract will effectively rule
out unlawful detainer as a remedy. As stated, in an action for unlawful
detainer, the defendant’s right to possess the property may be by virtue of a
contract, express or implied; corollary to this, the termination of the
defendant’s right to possess would be governed by the terms of the same
contract. Interpretation of the contract between the plaintiff and the
defendant is inevitable because it is the contract that initially granted the
defendant the right to possess the property; it is this same contract that the
plaintiff subsequently claims was violated or extinguished, terminating the
defendant’s right to possess. It was ruled in Sps. Refugia v.
CA[2] that –
[W]here the resolution of the issue of possession hinges on a determination of the validity and interpretation of the document of title or any other contract on which the claim of possession is premised, the inferior court may likewise pass upon these issues.
[1] Consignado v. Court of Appeals, G.R. No. 87148, March 18, 1992, 207 SCRA 297, 305-306, citing De la Cruz v. Court of Appeals, G.R. No. L-57454, November 29, 1984, 133 SCRA 520, 528; and Ching v. Hon. Antonio Q. Malaya, etc., et al., G.R. No. 56449, August 31, 1987, 153 SCRA 412.
[2] 327 Phil. 982, 1006 (1996).